Imel v. Commissioner
United States Tax Court
1. Held, the $ 5,000 loss that petitioner sustained in 1968 when a debt owed him became worthless was a nonbusiness bad debt within the meaning of sec. 166(d), I.R.C. 1954. 2. Held, the $ 30,000 loss that petitioner sustained in 1968 in settlement of his liability as a guarantor of a $ 100,000 note is not deductible under sec. 166(f) because the proceeds of the note were not used in the trade or business of the borrower. 3. Held, the $ 30,000 loss that petitioner sustained…
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1. Held, the $ 5,000 loss that petitioner sustained in 1968 when a debt owed him became worthless was a nonbusiness bad debt within the meaning of sec. 166(d), I.R.C. 1954. 2. Held, the $ 30,000 loss that petitioner sustained in 1968 in settlement of his liability as a guarantor of a $ 100,000 note is not deductible under sec. 166(f) because the proceeds of the note were not used in the trade or business of the borrower. 3. Held, the $ 30,000 loss that petitioner sustained in 1968 in settlement of his liability as a guarantor resulted from the worthlessness of a debt so that sec. 166, I.R.C.…
1Opinion of the Court
Robert E. Imel and Nancy J. Imel, Petitioners v. Commissioner of Internal Revenue, Respondent
Imel v. Commissioner
Docket No. 5799-70
United States Tax Court
61 T.C. 318; 1973 U.S. Tax Ct. LEXIS 12; 61 T.C. No. 34;
November 29, 1973, Filed
Decision will be entered under Rule 50.
1. Held, the $ 5,000 loss that petitioner sustained in 1968 when a debt owed him became worthless was a nonbusiness bad debt within the meaning of sec. 166(d), I.R.C. 1954.
2. Held, the $ 30,000 loss that petitioner sustained in 1968 in settlement of his liability as a guarantor of a $ 100,000 note is not deductible under…
2Cases cited19 opinions
- Whipple v. CommissionerSupreme Court of the United States · 1963
- Putnam v. CommissionerSupreme Court of the United States · 1956
- United States v. GeneresSupreme Court of the United States · 1972
- H. Beale Rollins and Mary E. Rollins v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1960
- Rushing v. CommissionerUnited States Tax Court · 1972
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